I actually have some really great news!
Our natural history study for San C was finally approved by the French Committee for the Protection of Persons and CNIL! You can find the study on NCT#05825131
I am over the moon excited to finally be green lighted to start this study. It’s a dream come true! Since we first formed JJB in 2009 our advisors stressed the importance of a natural history study. We were advise to document the course of the disease and the data could potentially serve as the control arm in a clinical trial. This is the first ever NHS for MPS IIIC.
Site Initiation Visit, November 6th 2024 |
Convincing the FDA to accept natural history as a control arm remains to be seen. Change is happening at the FDA; they are finally starting to understand the plight of the ultra-rare. The FDA told us to conduct a natural history study, we have it right there in our meeting minutes. There is one person at the FDA that is driving the issue, Peter Marks.
Dr. Marks is the director of CBER, this is the wing of the FDA that will review our gene therapy program. Last year, I had a nice face to face with Dr. Marks and shared with him the hurdles that San C would have in an interventional trial. I explained to him that San C was even more rare than A and B; diagnosing a child under the age of four without an older sibling being diagnosed first is virtually unheard of. Jonah being an exception.
Dr. Marks listened as I explained that the kids in our trials would be symptomatic, they would already have brain damage and the go-to cognitive assessments that the FDA reviewers trusted are not appropriate for evaluating our kids. Furthermore, our kids can be stable for years. I implored to him that it would be highly unlikely to show clinically meaningful change in a two-year trial and there was no way we could afford a trial that lasted more than 2 years. My ask was for him to encourage his reviewers to embrace the power bestowed on them and grant Accelerated Approval (AA). AA is given by the FDA when a drug demonstrates that it reduces a disease-causing biomarker. In our case that biomarker is Heparan Sulfate (HS). HS builds up in the lysosome of our children’s cells. AA allows the drug company to start selling the drug before full approval. This allows kids not in the trial to be treated and gives the drug company some revenue to finish out their trial. Push back from the FDA stems from concern that some drug companies will take advantage of AA. Just recently Ultragenyx received AA for its gene therapy program for the treatment of San A! This sets precedence for Phoenix Nest to follow.
With that said we still must find assessments that show meaningful change. I explained the symptoms of Sanfilippo to Marks and pointed out that we don’t have many endpoints that can be readily measured. Marks advised me to show the reviewers functional improvement. That’s where the video assessment portion of our natural history study comes into play.
We created a special protocol that will be used to assess children’s functional abilities at home. The protocol captures the children performing activities of daily living (ADL’s). Parents download a medical application onto their phone, consent to the study and follow the directions provided to them. The tech was designed by Aparito and is stored on HIPPA/GDPR compliant software. We named the app C-RARE, get it C as in Sanfilippo type C, C as in see. RARE stands for Recording Application of Real-world Evidence.
Sanfilippo kids have a really hard time sitting still and paying attention to a cognitive assessment administered in the clinic is not practical. With C-RARE we will capture the child’s true abilities in the comfort of their home. They’ll also visit the clinic and have numerous assessments done.
I must share with you the absolute nightmare of trying to get our NHS approved by the French ethics committee and CNIL. Let this story be a lesson for those that want to do the same.
Starting from the beginning.
In May of 2022 I went to France and met up with three French type C families at a family conference hosted by the patient organization VML. France is the perfect country to launch our first NHS site. It has the largest known patient population (except for Brazil) and a compassionate doctor who cares for patients living with San C. Dr. Guffon, is also experienced in running MPS trials. With the support of Dr. Guffon and help from Aparito, I pitched VML to help fund our NHS in France. The pitch was successful.
I went home and started working with Fortrea, our contract research organization. Fortrea manages our trial, they do the medical writing, submissions and regulatory oversight. We finished the protocol and informed consents and submitted to the French ethics committee in September of 2022. We didn’t receive approval until October 2024! Every time I talk to a parent they ask how long until we can go to interventional trial? Approval for a non-interventional trial took 2 years. I can only imagine how long it will take to get a protocol approved for an interventional trial. I want to start the regulatory process now!
The ethics approval process in France is different than the US, in France you’re sent to one of 13 different committees. It’s just luck of the draw. You then get two chances to answer two rounds of questions from the committee. If you don’t answer their questions to their satisfaction, you receive an ‘unfavorable’ opinion and are sent to a different committee to re-submit. If after two unfavorable submissions, you must start all over with a new protocol.
The committees don’t even look at the questions or responses from the other committees, as they are completely independent and therefore have their own opinions. So, expect a whole new round of questions.
Our first committee was obsessed with us collecting medical records from families of deceased children. They wanted us to take that out of the protocol. If we insisted on keeping it in the protocol, then we needed to have a clinical psychiatrist to help the families through the trauma of being asked to donate the records of their deceased child’s medical records. They said that it would be too hard on the families to be asked to participate in the study. They didn’t know it was a parent that designed the study. The reviewers also didn’t grasp why patients would want to participate in a study that didn’t offer a treatment. They questioned the importance for using so many cognitive and physical assessments. They didn’t have any concept of the hurdles that sponsors creating treatments for ultra-rare, slowly progressing, pediatric diseases were up against.
We had to explain everything in writing. They refused to talk to us on the phone and allow us to educate them on the importance of a NHS and why we had included so many assessments. We explained all this, then they came back and asked us a whole new set of questions. They set us up to fail. We couldn’t get through another set of questions without exhausting our two tries. They asked us to create a table within the protocol that broke down and explained each assessment and what it was measuring. We of course had already done this within the protocol in paragraph form. We asked them to be more specific in what they were asking, and they responded we just told you and that was it. So, we created the table and added it to the protocol. They came back and said we didn’t answer their question correctly and they kicked us to the curb. There were 24 questions in the first committee’s response. We had 2 weeks to respond to all of them and turn it around and have it back translated to French. The process is epic.
The second committee was obsessed with the informed consents. They didn’t like the tone in which the assessments were written. For instance, the infant informed consent was not dummied down to the point that it was baby talk. The adolescent consent was too babyish, and we needed to be more specific on potential risks of blood draw, CSF draw and MRI’s. Giving statistics on how often a CSF draw could cause a headache or the chances of bruising from a blood draw. Remember these patients can’t read or comprehend what the study is about, and the parents will ultimately consent to the study. In all we had to write 7 different informed consents/assents, each one tailored to the age range of the patient that would be ‘reading’ it. They were obsessed with pregnancy tests; would it be a blood or urine test? Where would we store the blood or urine? How would we address the pregnancy results with the patient and their caregiver? This review team didn’t act as if they knew that the patients had profound brain damage and would not be able to consent to intercourse, let alone read a consent form. At the end of the day, they refused us because they didn’t agree with the terminology, we used to describe the caregiver of a patient that was a ward of the state.
We had to start over, changing the name of the protocol, the study number and making the protocol slightly different so that it appeared to be new. You could imagine how mad I was. I screamed profanities into the emptiness of my office. The person that shares a wall with me won’t make eye contact with me when he sees me in the hall.
I informed the patient organizations that were supporting the study; Sanfilippo Sud and VML and sent them the comments. Guilhain, the president of Sanfilippo Sud and one of the co-founders of Phoenix Nest and HANDS took our plight to the French Ministry of Health.
Guilhain read that Oliver Veran the government spokesperson and previous minister of health would be speaking at an event near him. Guilhain went to the event, he worked his way through the crowd and grabbed Veran’s attention. He was given five minutes to speak to Dr. Veran, Veran was moved by our story and put him in touch with the current Minister of Health. Guilhain, was then able to walk the representative through the ethics approval process and share with them the comments of the first two committees. He was told that they couldn’t tell the ethics committee what to do, but they would certainly investigate it.
We resubmitted in July; we had to wait out all of August because everyone in France goes on holiday in August. They reviewed our protocol and informed consents on the 9th of September and turned around and gave us comments within two days of reviewing our submissions. They asked a couple of minor questions; they didn’t ask us to change anything on the protocol. They did ask us to shorten and combine the informed consents that they were too long for a patient that didn’t have the cognitive capacity to read them and there were too many of them. Go figure…. We fixed the consents and that was it, 2 days later we were given approval.
We lost two years and tens of thousands of dollars trying to satisfy the ethics committee. This family here have 2 children, the youngest is the youngest known child in the world. We just lost two years of his life. Nice work people.
We are now in the process of opening a second site in the US at UT Southwestern, Texas. The process is intense as well, we have been warned that it will most likely take 6 months. Our submission date is December 23rd, with any luck we will be enrolling this summer.
Meanwhile, the pre-clinical safety and dose ranging mouse study we started last year is wrapping up. There was concern at the beginning because our mouse model ended up being less severe than we had anticipated. It took longer for us to see behavioral changes in the animals. Fortunately, everything fell into place. Our mice finally got sick, and we were able to show behavioral and survival improvement between our treated and nontreated mice. All the mice are being taken down now and will be shipped off to Australia, where Dr. Fuller will be doing the all-important work of analyzing Heparan Sulfate levels. Woohooo! Next week will kick off the start of the toxicology study. While that study is underway, we hope to write and take our clinical package to the FDA for comments. We need substantial funds for the clinical writing and the clinical grade vector production. Our current NIH grant isn’t enough to pay for the work. With the toxicology data and the data from the mice behavioral and dosage study, combined with the HS analysis we will write yet another grant. I’m confident that we will score high enough to be awarded the grant. Unfortunately, the process of writing and waiting for the NIH grant to be funded will add an extra year to our timelines. Secondly, I’m terrified that the new administration will cut funding to the NIH and we won’t be able to secure federal grants.
I’m very happy with our progress and I expect that we will soon have a clear picture of our path to the clinic. I look forward to updating you in another 6 months.
If so, moved you can help
keep our studies on track by donating to my Giving Tuesday fundraiser.